I want to outline some of the concerns I have with the proposed changes to the regulations.

• Changes with bringing services to a more clinic based setting will exclude families that are unable to come to a clinic due to transportation issues, concerns with COVID/other health concerns or scheduling issues. Families and clients that have a lower socioeconomic status and/or live-in rule areas will be at a disadvantage with some of the new proposed changes
• Limiting time allotted for treatment planning will allow for agencies to create templates for objectives/goals and will decrease the individualized goals that are best for the families and clients. Forcing treatment planning to only occur in the presence of clients will decrease a LBA/LABA’s ability to research and process through more effective objectives and interventions due to limited ability to focus on treatment planning vs observation of client
• Wording excluding LABAs from providing treatment planning and supervising will increase workloads and case loads on existing LBAs and will increase waitlists, decreasing the number of clients being served
• Pay out for clinicians to be decreased will affect pay rates, salary style pay for clinicians which will be a deterrent for more experienced staff and will force less experienced staff to assume those roles due to pay.

Overall, the proposed changes will drastically increase waitlists, allowing smaller number of clients to be effectively and successfully served due to restrictions on treatment.